We describe one case of hepatocellular carcinoma (HCC) arising in secondary haemochromatosis in a non-cirrhotic liver. The patient was a 40-year-old male. He had severe pancytopenia due to myelodysplastic syndrome (MDS) and developed secondary haemochromatosis as a result of a large amount of erythrocyte transfusion. Multiple nodules of the liver appeared about 6 years after the diagnosis of MDS. Needle biopsy of the nodules histologically confirmed them to be moderately differentiated HCCs. The liver parenchyma was shown to be non-cirrhotic and a deposit of hemosiderin was also identified, consistent with a finding of haemochromatosis of the liver. Transarterial chemoembolization was performed to treat multiple HCCs. There are a number of reports describing HCC occurrence in non-cirrhotic patients with hereditary haemochromatosis. However, HCC in secondary haemochromatosis without cirrhosis is extremely rare.